Office of Foreign Assets Control

News & Analysis as of

Banks and the EB-5 Program: Look Before You Leap

Many Washington banks have been asked to serve either as lender for an EB-5 project or as escrow holder to receive EB-5 customer deposits. While the benefits of serving in such roles, especially for a large real estate...more

Sanctions Round-Up: Third Quarter 2014

In this issue: - The Revised OFAC 50 Percent Rule - U.S. and E.U. Sectoral Sanctions Targeting Russia - Additional U.S. Sanctions Targeting Iran - Sanctions Targeting Ongoing Conflicts in Syria,...more

Sanctions Relating to Russia Imposed by the U.S., EU, Australia and Japan - A Snapshot of Where We Are Now

Since early March 2014, a number of countries have imposed various types of sanctions against Russia and certain persons in Ukraine in connection with events in Ukraine. We have issued a series of updates covering, in...more

Accounts and Accountability: Arab Bank Found Liable for Transactions Under the Anti-Terrorism Act

On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more

Test Your Knowledge on OFAC Sanctions

Global sanctions have shot up the scale of high risks to be prioritized by international companies and financial institutions, including real estate, corporate and trust service provider businesses. The battle against...more

OFAC Issues New General License Excepting Turkish Lender from Russian Sanctions

On October 6, 2014, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License No. 3, excepting DenizBank AS, a Turkish lender, from the restrictions on access to new debt or new equity under...more

FinCrimes Update - September 2014 Summary, Volume 1, Issue 7

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. BSA/AML & OFAC: FINCEN OFFERS RED FLAGS GUIDANCE ON HUMAN TRAFFICKING AND...more

OFCCP’s New Scheduling Letter and Expanded Itemized Listing

As many federal contractors know, the Office of Federal Contract Compliance Programs (OFCCP) begins a compliance evaluation (or audit) by sending to the selected contractor a letter scheduling the audit. The listing of...more

Recent Trends in DOJ Investigations Against Major Financial Institutions Involving U.S. Economic Sanctions

With the imposition of billion-dollar fines against large financial institutions, the U.S. Department of Justice ("DOJ") is focusing on banks for not only failing to comply with federal laws, but also for willfully violating...more

Overview of the U.S. and EU Sanctions on Russia

Over the past six months, the United States and the European Union have coordinated efforts through sanctions and trade controls to respond to Russian activity in Crimea and Ukraine. Following a long series of incremental...more

Complicating Sanctions Compliance: OFAC Redefines 50 Percent Rule

Companies are worried more and more about sanctions compliance. As the number and complexity of sanctions grow, depending on the twists and turns of our foreign policy, companies are whipsawed in the area of sanctions...more

U.S. Steps Up Sanctions and Export Controls Against Russia’s Defense Industry

The United States recently expanded sanctions and export controls against the Russian defense sector. These designations and export control steps have implications for defense contractors, parts suppliers and brokers....more

17 Red Flags for Potential International-Sanctions Violations

Recent events in Ukraine and the Middle East have expanded sanctions placed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) against certain foreign financial institutions and individuals. This...more

Update on U.S. Sanctions Relating to Ukraine

U.S. Sanctions - On September 12, the United States, in coordination with the EU, imposed additional sanctions against Russia in connection with events in Ukraine. Specifically... - the Office of Foreign Assets...more

New US sanctions on Russia’s financial, defense and energy sectors impact US companies

The US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued additional sanctions targeting certain Russian banks, energy and defense companies. The sanctions, issued September 12, 2014, are intended to...more

New U.S. Restrictions on Russia: OFAC Guidance and Industry-Specific Sanctions

OFAC Expands the 50 Percent Rule - Last month, the Department of Treasury’s Office of Foreign Assets Control (OFAC) released new guidance related to entities owned or controlled by persons designated as a Specially...more

OFAC Fines Commodity Trading Advisor For Apparent Sanctions Violations

On September 9, OFAC released an enforcement action against a CFTC-registered Introducing Broker and Commodity Trading Advisor that operates an electronic trading platform that allows customers to automatically place currency...more

FinCrimes Update - August 2014 Summary, Volume 1, Issue 6

In This Issue: - BSA/AML & OFAC - Virtual Currency & Payment Systems - FCPA & Anti-Corruption - Criminal Enforcement - Excerpt from BSA/AML & OFAC: FINCEN PUBLISHES LONG-AWAITED...more

Bank Settles With OFAC Regarding Civil Action for Apparent Violation of Sudanese Sanctions Regulations

The Office of Foreign Assets Control (“OFAC”) posted a summary of a settlement with a bank (the “Bank”) relating to a transaction that OFAC alleged was processed by the Bank in violation of OFAC’s Sudanese Sanctions...more

OFAC Makes Important Update to Ownership/Control Guidance

On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more

Revised OFAC Guidance on "Shadow" SDNs

OFAC expands the scope of its 50% rule. On August 13, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued “Revised Guidance on Entities Owned by Persons Whose Property and Interests in...more

OFAC Revises the “50% Rule” with Regards to Aggregate Ownership

On August 13, 2014, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued revised guidance relating to the status of entities owned by individuals or entities whose property and...more

OFAC Issues Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are Blocked

The Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has issued revised guidance with respect to entities owned 50 percent or more in the aggregate by one or more blocked persons....more

OFAC Issues New Guidance Regarding Status of Entities Owned by Specially Designated Nationals and Blocked Persons

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new guidance regarding the status of entities that are 50% or more owned by persons or entities whose property and interests in property are...more

New OFAC Guidance on 50% Rule Expands Reach of US Sanctions

The U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) revised its guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked persons. The new guidance, issued on...more

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